Draft 

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

REVIEW OF THE SUMMARY SITE PROFILE FOR THE 

PACIFIC PROVING GROUNDS, REVISION 01, JULY 11, 2016

Contract No. 211-2014-58081 

SCA-TR-2016-SP009, Revision 0 

Prepared by

U. Hans Behling, PhD, MPH 

SC&A, Inc.

1608 Spring Hill Road, Suite 400 

Vienna, Virginia, 22182 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

December 2016

DISCLAIMER

This is a working document provided by the Centers for Disease Control and Prevention (CDC) 

technical support contractor, SC&A for use in discussions with the National Institute for 

Occupational Safety and Health (NIOSH) and the Advisory Board on Radiation and Worker Health 

(ABRWH), including its Working Groups or Subcommittees. Documents produced by SC&A, such as 

memorandum, white paper, draft or working documents are not final NIOSH or ABRWH products or 

positions, unless specifically marked as such. This document prepared by SC&A represents its 

preliminary evaluation on technical issues. 

NOTICE: This report has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

2 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

SC&A, INC.: Technical Support for the Advisory Board on Radiation and Worker 

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: 

Review of the Summary Site Profile for the Pacific Proving Grounds, 

Revision 01, July 11, 2016

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2016-SP009 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: December 21, 2016

TASK MANAGER: U. Hans Behling, PhD, MPH [signature on file]

PROJECT MANAGER: John Stiver, MS, CHP [signature on file]

DOCUMENT 

REVIEWER(S):

Kathleen Behling [signature on file]

John Stiver, MS, CHP [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 12/21/2016 Initial issue
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

3 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

TABLE OF CONTENTS

Abbreviations and Acronyms ..........................................................................................................4

1.0 Statement of Purpose ...........................................................................................................5

2.0 Relevant Background Information .......................................................................................5

2.1 Technical Approach and Review Criteria ............................................................... 5

2.2 Chronology of Relevant Prior Events ..................................................................... 5

3.0 Review of ORAUT-TKBS-0052, Revision 01, for Resolution of Findings 1 through 9 and 

Observation 1 ................................................................................................................7

4.0 Summary Conclusions .......................................................................................................11

5.0 References ..........................................................................................................................12

Appendix A: Issues Resolution Matrix for Pacific Proving Ground Site Profile 

(NIOSH 2014) ............................................................................................................13
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

4 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

ABBREVIATIONS AND ACRONYMS

Advisory Board Advisory Board on Radiation and Worker Health 

A/P anterior/posterior 

AWE Atomic Weapons Employer 

CDC Centers for Disease Control and Prevention 

DNA Defense Nuclear Agency 

DOE U.S. Department of Energy 

DOL U.S. Department of Labor 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

ISO isotropic 

keV kiloelectron volt 

MDA minimum detectable activity

NIOSH National Institute for Occupational Safety and Health

NRC National Research Council

NTS Nevada Test Site 

ORAUT Oak Ridge Associated Universities Team

POC probability of causation 

PPG Pacific Proving Grounds 

ROT rotational 

SAIC Science Applications International Corporation 

SEC Special Exposure Cohort 

SRDB Site Research Database 

TBD technical basis document 

U.S.C. United States Code 

WG work group
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

5 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

1.0 STATEMENT OF PURPOSE

This draft report presents SC&A’s evaluation of the recently revised Summary Site Profile for 

the Pacific Proving Ground (ORAUT-TKBS-0052, Revision 01 [ORAUT 2016]). This draft 

report was prepared at the request of the Advisory Board on Radiation and Worker Health 

(Advisory Board). Authorization for the preparation of this report was issued during a full 

Advisory Board meeting held in Idaho Falls, Idaho, on August 9 and 10, 2016. 

2.0 RELEVANT BACKGROUND INFORMATION

2.1 TECHNICAL APPROACH AND REVIEW CRITERIA

The standard approach used by SC&A to perform site profile reviews includes, but is not limited 

to, the procedural protocols described in Standard Operating Procedure for Performing Site 

Profile Reviews (SC&A 2004). Approved by the Advisory Board on March 18, 2004, SC&A’s 

protocol reflects the following review criteria:

1. Completeness of data sources

2. Technical accuracy

3. Adequacy of data 

4. Consistency with other site profiles 

5. Regulatory compliance

2.2 CHRONOLOGY OF RELEVANT PRIOR EVENTS

The following is a timeline of events leading to the enclosed review of ORAUT-TKBS-0052, 

Revision 01, issued July 11, 2016: 

• On August 30, 2006, the National Institute for Occupational Safety and Health (NIOSH) 

issued ORAUT-TKBS-0052, Revision 00, Summary Site Profile for the Pacific Proving 

Ground (ORAUT 2006). 

• In June 2012, at the request of the Advisory Board, SC&A was tasked to conduct a 

review of Revision 00 to the Pacific Proving Grounds (PPG) site profile.

• SC&A issued its first draft review of ORAUT-TKBS-0052, Revision 00, to the Advisory 

Board on October 21, 2013, as SCA-TR-SP2013-0040, Revision 0, Review of the 

Summary Site Profile Review for the Pacific Proving Grounds (SC&A 2013a). 

SC&A’s draft review identified a total of nine findings and one observation. Among the findings, 

Finding 1 questioned the 250-day Special Exposure Cohort (SEC) requirement for PPG 

participants and made the following recommendation: 

The site profile should make an affirmative statement regarding a reduced time 

period onsite at PPG that may potentially substitute as the equivalence of the 

250 day for the purpose of designating a PPG worker as part of an SEC. 

[SC&A 2013a] 
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

6 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

The 250-day PPG SEC requirement was revised after Revision 00 to ORAUT-TKBS-0052, 

which was issued on August 30, 2006. Revision 00 predates Energy Employees Occupational 

Illness Compensation Program Act (EEOICPA) Bulletin No. 06-15 and EEOICPA Bulletin 

No. 07-05, which were issued on September 27, 2006, and January 22, 2007, respectively, by the 

U.S. Department of Labor (DOL). Bulletin No. 06-15 and No. 07-05 amended the 250-workday 

requirement for PPG participants to 83 days. 

In order to address and explain this new information, the Advisory Board asked SC&A to revise 

and reissue its review of ORAUT-TKBS-0052, Revision 00. 

• In November 2013, SC&A issued its revised review of ORAUT-TKBS-0052, 

Revision 00, as SCA-TR-SP2013-0040, Revision 1 (SC&A 2013b). 

• In response to SC&A’s revised draft review (SC&A 2013b) of the PPG site profile 

(ORAUT-TKBS-0052, Revision 00), NIOSH issued an Issues Resolution Matrix for 

Pacific Proving Ground Site Profile on May 20, 2014.

As a convenience to the reader, NIOSH’s May 2014 issues resolution matrix is enclosed 

herein as Appendix A. Appendix A briefly summarizes each of the nine findings and one 

observation identified by SC&A and their corresponding resolutions proposed by 

NIOSH.

• On January 16, 2015, the Pacific Proving Grounds Work Group (PPG WG) convened a 

teleconference that also included the participation of personnel representing NIOSH, its

contractors, and SC&A. Members of the PPG WG weighed the merits of each of SC&A’s 

findings and observation and critically assessed the adequacy of NIOSH’s proposals for 

their resolution. 

On the basis of data presented, the PPG WG concluded that NIOSH’s proposed 

resolutions adequately addressed SC&A’s concerns and assigned the status of all findings 

to be “In Abeyance.” The status of “In Abeyance” requires that, for final “Closure” of a 

finding, NIOSH is required to revise ORAUT-TKBS-0052 in compliance with the stated 

proposed resolutions. 

• On July 11, 2016, NIOSH issued Revision 01 to ORAUT-TKBS-0052 for SC&A’s 

review.

• During a full Advisory Board meeting held August 9 and 10, 2016, SC&A was requested 

to conduct a review of ORAUT-TKBS-0052, Revision 01, that focuses exclusively on 

findings “In Abeyance” for their resolution in a future PPG WG meeting. 
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

7 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

3.0 REVIEW OF ORAUT-TKBS-0052, REVISION 01, FOR

RESOLUTION OF FINDINGS 1 THROUGH 9 AND

OBSERVATION 1 

Resolution of the findings held “In Abeyance” involves an assessment of the revised text in the 

PPG site profile for the purpose of confirming that the full intent of NIOSH’s proposed 

resolution has been met, as stated in Appendix A. The following list summarizes each finding 

and briefly describes NIOSH’s revisions to the text and the resultant status for each finding. 

• Finding 1: NIOSH needs to update ORAUT-TKBS-0052, Revision 00, with regard to the 

250-workday requirement for SEC class inclusion based on EEOICPA Bulletin 

No. 06-15 and No. 07-05. 

NIOSH Resolution of Finding 1. Section 1.3 of ORAUT-TKBS-0052 was amended in 

accordance with provisions of EEOICPA Bulletin No. 06-15 (DOL 2006) and EEOICPA 

Bulletin No. 07-05 (DOL 2007), which equate any 24-hour period (spent working or 

living on the PPG) to be equivalent to three 8-hour work days for establishing the 

250-workday requirement for potential inclusion in the SEC class. 

Status of Finding 1. SC&A agrees with the text revision and recommends closure of 

Finding 1. 

• Finding 2: Section 4.0, “Occupational Environmental Dose,” ignores occupational 

environmental doses for PPG locations from fallout. 

NIOSH Resolution of Finding 2. SC&A’s concern about the definition and quantitative 

assessment of exposure to fallout prior to 1955 (when participants were issued permanent

film badges) was briefly acknowledged in Section 4.0, “Occupational Environmental 

Dose.” Definitive guidance for the assignment of unmonitored external exposure to 

fallout prior to 1955 is provided in revisions to Sections 6.2 and 6.3 and Attachment A to

the PPG site profile. 

Status of Finding 2. Revision to Section 6.0 provides the necessary guidance to account 

for unmonitored external exposures to fallout prior to 1955. SC&A recommends closure 

of Finding 2. 

• Finding 3: Available U.S. Department of Energy (DOE) records for a claimant may not 

only be incomplete/inaccurate but, more importantly, may not include unmonitored 

exposures associated with cohort badging, exposure to fallout, etc. 

Finding 4: ORAUT-TKBS-0052 does not provide a definition for unmonitored dose as it 

applies to PPG participants or any specific guidance.

Finding 8: Independent of other concerns and limitations that characterize the Defense 

Nuclear Agency (DNA) dose distribution data (e.g., their accuracy, completeness, etc.), 

use of the 50th percentile dose as a coworker dose is not justified for PPG participants for 

operations up to and inclusive of Operation CASTLE. 
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

8 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

Finding 9: Operation-specific dose distributions defined by DNA must be adjusted to 

account for the minimum detectable activity (MDA) value of film dosimeters regardless 

of what percentile value is employed.

NIOSH Resolution of Findings 3, 4, 8, and 9. Generic limitations associated with

personal dosimeters, their limited use/assignment to personnel during select time periods, 

and other procedural practices were recognized by NIOSH as deficiencies that are 

“intractable.” To overcome these deficiencies, NIOSH proposes the optional use of the 

95th percentile coworker doses defined in Attachment A of the revised PPG site profile.

Status of Findings 3, 4, 8, and 9. In Section 3.0, “Relevant Background Information,” of 

SC&A’s Review of the Summary Site Profile for the Pacific Proving Grounds, Revision 1 

(SC&A 2013b), SC&A fully recognized the difficulties NIOSH faced in the dose 

reconstruction of PPG personnel by providing the following statements: 

[SC&A’s] purpose of presenting the aforementioned statistics is to point 

out the magnitude and dynamics of the PPG testing program and the 

demands and limitations it placed on personnel and resources that were 

further complicated by the remote/isolated locations that characterize the 

four test sites of the PPG.

Undoubtedly impacted by unexpected events, limited resources, and 

adverse operating conditions were RadSafe personnel. Their charter was 

to provide radiological surveillance and personnel monitoring for tens of 

thousands of personnel assigned to the PPG program. 

Given the intractable nature of said limitations, SC&A believes that the use of coworker 

dose values cited in Attachment A of the PPG site profile, Revision 01, is a reasonable 

resolution. Accordingly, SC&A recommends closure of Findings 3, 4, 8 and 9. 

• Finding 5: Average photon energies associated with fallout are well above 

>250 kiloelectron volts (keV). Depending on what exposure geometry is assumed, a 

default photon energy of 30–250 keV may not be claimant favorable.

NIOSH’s Resolution of Finding 5. From a purely factual viewpoint (and openly 

acknowledged by NIOSH), external photon energy and exposure geometry at the PPG 

did involve photon energies >250 keV and geometries other than anterior/posterior (A/P). 

However, NIOSH’s choice of (1) the 30–250 keV photon energy and (2) the AP exposure 

geometry for dose reconstruction was defended by the fact that for all but four organs 

(lung, esophagus, red bone marrow, and bone marrow), the corresponding dose 

conversion factor (DCF) values were higher and, therefore, more claimant favorable. For 

these four organs, revisions in Section 6.3.3 suggest that an AP-to-rotational (ROT) 

geometry ratio should be considered for claimant favorability with isotropic (ISO) 

geometry for cases requiring best estimates.

Status of Finding 5. The issue of a higher photon energy at the PPG was discussed at 

length during the January 16, 2015, teleconference. Given the fact that the lower photon 
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

9 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

energy and AP geometry assumed by NIOSH generally yield higher DCF/probability of 

causation (POC) values (for most, but not all, organs), SC&A agrees that NIOSH should 

retain its “general approach with all EEOICPA claims [which] is to apply the DCF 

yielding the highest POC” (NIOSH 2014). In support of claimant favorability, SC&A 

therefore withdraws Finding 5 and recommends closure.

• Finding 6: Because claims involving skin cancer usually specify the locations on the 

body, the critical variable of distance above the source plane defined by Barss and Weitz 

(2006) should be included in the assignment of beta-to-gamma dose ratios for PPG 

claimants.

NIOSH’s Resolution of Finding 6. SC&A notes that the ratio of beta to gamma dose 

associated with exposure to fallout is highly variable with the age of the fallout, as well 

as the distance above the source plane. In the absence of dosimeter-beta dose, this 

variability is of critical importance for claims involving skin cancers and other surficial 

tissues. In Section 6.1 of the revised PPG site profile, NIOSH eliminated the default 

Nevada Test Site (NTS) beta-to-gamma ratios of 1:1 and revised guidance that included 

beta-to-gamma ratios by Barss and Weitz (2006) along with efficiency ratios that include 

the effects of weathering.

Status of Finding 6. Revisions incorporated in Section 6.1 fully address critical variables 

that include age of fallout, distance, and weathering impacts on the beta-to-gamma ratios 

that must be used to derive the beta dose contribution for selection tissues. SC&A agrees 

with the revisions to Section 6.1 and recommends closure of Finding 6. 

• Finding 7: NIOSH’s guidance for the assignment of missed dose is based on assumptions 

that are not supported by facts and, in the face of uncertainty, are clearly not claimant 

favorable.

NIOSH’s Resolution of Finding 7. This finding pertains to deficiencies in the assignment, 

processing, and interpretation of film badges for years prior to 1955 and that limit 

NIOSH’s ability to estimate missed doses. To account for unmonitored exposures and the 

uncertainties of recorded exposures, NIOSH revised Section 6.0 of the PPG site profile 

with the following guidance: 

To account for these large uncertainties, the 95th percentile coworker 

doses in Attachment A should be assigned for cases in which the data are 

incomplete or nonexistent. If before 1955, the employee had recorded 

dose, the dose reconstruction should compare that recorded dose with the 

95th percentile doses in Attachment and assign the larger of the two doses. 

Status of Finding 7. In Sections 6.1, 6.2, and 6.3 of the revised PPG site profile, NIOSH 

also addressed exposures to fallout associated with Operation Greenhouse in 1951 for 

personnel stationed on the base islands of Enewetak, Parry, and Japtan, as well as for 

personnel assigned to naval support vessels. SC&A has assessed the revision to Section 6 

of ORAUT-TKBS-0052 in the context of the stated findings. SC&A concludes that 

current guidance adequately addresses Finding 7 and recommends its closure.
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

10 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

• Observation 1. There is a need for more definitive guidance pertaining to the assignment 

of occupational medical dose in behalf of claimants with no formal affiliation with a 

DOE or Atomic Weapons Employer (AWE) facility.

NIOSH’s Resolution to Observation 1. SC&A’s concerns for the need to provide more 

definitive guidance on assignment of occupational medical dose was addressed by 

NIOSH in revisions to Section 3.0, which substituted protocols defined in ORAUTPROC-0061, Occupational X-Ray Dose Reconstruction for DOE Sites, Revision 00 

(ORAUT 2004), for guidance provided in ORAUT-OTIB-0079, Guidance on Assigning 

Occupational X-Ray Dose under EEOICPA for X-Rays Administered Off Site, 

Revision 00 (ORAUT 2011a). 

Status of Observation 1. SC&A concurs with text revision to Section 3.0 and 

recommends closure of Observation 1. 
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

11 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

4.0 SUMMARY CONCLUSIONS

This report summarizes SC&A’s focused review of ORAUT-TKBS-0052, Revision 01, with 

regard to changes that address nine findings and one observation identified in SC&A’s draft 

review of ORAUT-TKBS-0052, Revision 00. These site profile changes correspond to proposed 

resolutions that were presented to and accepted by the PPG WG pending proper revisions to the 

PPG site profile.

SC&A concurs with said revisions and recommends closure of all findings and the observation. 
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

12 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

5.0 REFERENCES

Barss and Weitz 2006. N.M. Barss and R.L. Weitz, “Reconstruction of External Dose from Beta 

Radiation Sources of Nuclear Weapon Origin,” Health Physics, Vol. 91, No. 4 (2006), pp. 379–

389. [SRDB Ref. ID 26776]

DOL 2006. Processing Claims for the Pacific Proving Grounds SEC Class, 1946 – 1962, 

EEOICPA Bulletin No. 06-15, U.S. Department of Labor, Washington, DC. September 27, 2006. 

[SRDB Ref. ID 155208] 

DOL 2007. Supplemental Guidance for Processing Claims for the Pacific Proving Grounds SEC 

Class, 1946 – 1962, EEOICPA Bulletin No. 07-05, U.S. Department of Labor, Washington, DC. 

January 11, 2007. [SRDB Ref. ID 131050] 

NIOSH 2014. Issues Resolution Matrix for Pacific Proving Ground Site Profile, National 

Institute for Occupational Safety and Health, Cincinnati, Ohio. May 20, 2014. 

ORAUT 2004. Occupational X-Ray Dose Reconstruction for DOE Sites, ORAUT-PROC-0061, 

Revision 00, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. December 1, 

2004. 

ORAUT 2006. Summary Site Profile for the Pacific Proving Ground, ORAUT-TKBS-0052, 

Revision 00, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. August 30, 2006. 

ORAUT 2011a. Guidance on Assigning Occupational X-Ray Dose Under EEOICPA for X-Rays 

Administered Off Site, ORAUT-OTIB-0079, Revision 00, Oak Ridge Associated Universities 

Team, Oak Ridge, Tennessee. January 3, 2011. 

ORAUT 2011b. Use of Coworker Dosimetry Data for External Dose Assignment, ORAUTOTIB-0020, Revision 03, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee.

November 14, 2011. 

ORAUT 2016. Summary Site Profile for the Pacific Proving Ground, ORAUT-TKBS-0052, 

Revision 01, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee. July 11, 2016. 

SC&A 2004. Standard Operating Procedure for Performing Site Profile Reviews, Revision 1, 

S. Cohen & Associates, McLean, Virginia. May 13, 2004. 

SC&A 2013a. Review of the Summary Site Profile Review for the Pacific Proving Grounds, 

SCA-TR-SP2013-0040, Revision 0, S. Cohen & Associates, Vienna, Virginia. October 21, 2013. 

SC&A 2013b. Review of the Summary Site Profile Review for the Pacific Proving Grounds, 

Revision 1, SCA-TR-SP2013-0040, Revision 1, S. Cohen & Associates, Vienna, Virginia. 

November 5, 2013. 
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

13 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

APPENDIX A: ISSUES RESOLUTION MATRIX FOR PACIFIC 

PROVING GROUND SITE PROFILE (NIOSH 2014)

Finding

Number

Report 

Section Finding Description NIOSH Response

1 4 

NIOSH needs to update ORAUTTKBS-0052, Rev. 00, with regard to 

the 250-workday requirement for 

SEC Class inclusion. Revision 00 of 

ORAUT-TKBS-0052, Summary Site 

Profile for the Pacific Proving 

Grounds, was issued on August 30, 

2006. At that time, SEC status for 

presumptive cancer claimants 

required employment with at least 

250 workdays. The 250-workday 

requirement for PPG workers was 

subsequently amended by the 

Department of Labor (DOL) in 

EEOICPA Bulletin No. 06-15 issued 

on September 27, 2006, and 

EEOICPA Bulletin No. 07-05 issued 

on January 11, 2007. Additionally, 

there may be a need for further 

discussions pertaining to the 

surrogate use of film badge 

dosimetry for PPG employment 

period(s) as recommended in DOL’s 

EEOICPA Bulletin No. 07-05. 

NIOSH agrees than an update is needed to 

ORAUT-TKBS-0052, Rev. 00, with regard to 

the 250-workday requirement for SEC Class 

inclusion. The next revision of ORAUT-TKBS0052 will include provisions of EEOICPA 

Bulletin No. 06-15 issued on September 27, 

2006, and EEOICPA Bulletin No. 07-05 issued 

on January 11, 2007 which state, inter alia, that: 

“For any 24-hour period that the employee was 

present (either worked or lived) on the PPG or on 

ships (evacuated prior to a nuclear weapon 

testing), the CE would credit the employee with 

the equivalent of three (8-hour) work days. If 

there is evidence the employee was present at the 

PPG or on ships for 24 hours in a day for 83 

days, the employee would have the equivalent of 

250 work days and would meet the 250 work day 

requirement.” 

Observation

1 

5 

There is a need for more definitive 

guidance pertaining to the 

assignment of occupational medical 

dose in behalf of claimants with no 

formal affiliation with a DOE or 

AWE facility.

The next revision of ORAUT-TKBS-0052 will 

include provisions from ORAUT-OTIB-0079 

which states the NIOSH interpretation is that the 

EEOICPA defines covered radiation as the 

radiation received by a covered employee at a 

covered facility during a covered period. Section 

2.0 of ORAUT-OTIB-0079 also states that “For 

most cases in which energy employee medical 

records are not provided, dose reconstructors 

should assume that any occupational medical Xray exposure occurred at the covered facility 

where the energy employee worked.” Therefore, 

if a covered employee cannot be affiliated with a 

covered facility and there are no records of Xrays being administered at a covered facility, 

then occupational medical exposures should not 

be assigned. 

In addition, the next revision of ORAUT-TKBS0052 will delete reference to the guidance found 

in ORAUT-PROC-0061 for covered employees 

“hired on location.” 
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

14 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

Finding

Number

Report 

Section Finding Description NIOSH Response

2 6 

Section 4.0 “Occupational 

Environmental Dose” completely 

ignores occupational environmental 

doses for PPG locations from fallout.

(Note: For PPG locations, 

occupational external environmental 

dose is for all practical purposes an 

integral part of the occupational 

external (as well as internal) dose 

and should be assessed as such in 

Section 6.0 of the PPG Site Profile.)

NIOSH agrees with the finding and Section 4 of 

the next revision of ORAUT-TKBS-0052 will be 

revised to instruct dose reconstructors that 

external dose should be assessed in Section 6.0 

of the PPG Site Profile. Under the current SEC, 

in the absence of bioassay data, internal doses 

cannot be reconstructed. 

3 7.4.2 

Available DOE records for a 

claimant may not only be 

incomplete/inaccurate, but more 

importantly may not include 

unmonitored exposures associated 

with cohort badging, exposure to 

fallout, etc.

NIOSH understands there are serious 

deficiencies related to film badge dosimetry data 

and procedural practices identified by the NRC 

(1989), SAIC (1989 – 2006), and Perkins and 

Hammond (1980). In light of these deficiencies, 

NIOSH finds it intractable to achieve more 

accurate dose assessments than those provided 

by the DNA and reduced in Attachment A of 

ORAUT-TKBS-0052, with realistic uncertainty 

ranges; too many data have been lost or never 

captured to make such an effort feasible.

However, the next revision ORAUT-TKBS-0052 

will include revisions to the Attachment A to 

provide 95% doses as appropriate (see response 

to Findings 8 and 9 below). For cases where 

occupation on the various islands is documented 

in the dosimetry records and their stay times are 

known, either by personal or cohort film badges 

or reentry logs, additional dose can be calculated 

in accordance with the information provided in 

Figures 7-6 through 7-10 and added to doses 

assigned using Attachment A to account for 

unmonitored exposure to fallout. It should be 

noted that during Operation Castle in the first 

half of 1954, 85% to 90% of all personnel were 

issued operational film badges. In addition, all 

personnel involved in reentry activities were also 

issued mission badges that were read at the end 

of each mission. (Castle Series, 1954, DNA 

6035F). For Operation Wigwam on May 15, 

1955, and all subsequent tests at PPG, 100% of 

all personnel were issued operational film 

badges. In addition, all personnel involved in 

reentry activities were also issued mission 

badges that were read at the end of each mission. 

(Wigwam, DNA 6000F, 1981) 
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

15 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

Finding

Number

Report 

Section Finding Description NIOSH Response

4 7.4.2 

ORAUT-TKBS-0052 does not 

provide a definition for unmonitored 

dose as it applies to PPG participants 

or any specific guidance.

The next revision of ORAUT-TKBS-0052 will 

revise this statement to read as follows:

“Covered employees that participated in the 

various PPG operations and were not badged can 

be assigned coworker dose as outlined in 

Attachment A.”

5 7.4.2 

Average photon energies associated 

with fallout are well above >250 

keV. Depending on what exposure 

geometry is assumed, a default 

photon energy of 30–250 keV may 

not be claimant favorable

Although ISO or ROT geometries might be more 

realistic, the general approach taken with all 

EEOICPA claims is to apply the DCF yielding 

the highest POC. Except for the lung, esophagus, 

red bone marrow, and bone surfaces (as 

discussed in IG-001, Section 4.4) the highest 

DCF is typically associated with the 30-250 keV 

photon energy range and the AP geometry. In 

addition, as described in Table 5A of the NIOSH 

–IREP Technical Documentation (2002), the 

radiation effectiveness factor (REF) is 

significantly higher for photons in the 30-250 

keV range when compared to the > 250 keV 

range. These two factors lead to the 

recommendation given in Section 6.0. 

6 7.4.2 

Since claims involving skin cancer 

usually specify the location(s) on the 

body, the critical variable of distance 

above the source plane defined by 

Barss and Weitz (2006) should be 

included in the assignment of betato-gamma dose ratios for PPG 

claimants.

Figure C-1 in Attachment C of the NTS external 

TBD provides the information given in Table 7-4 

of the SC&A report. In addition, with respect to 

the ratios in Table C-1 of the NTS document, 

Attachment C recommends: “These values can 

be modified with appropriate factors for 

shielding and distance (Barss and Weitz 2006).” 

Guidance on the assignment of beta-to-gamma 

ratios from Barss and Weitz (2006) will be added 

to the next revision of ORAUT-TKBS-0052 for 

clarity. The guidance will include, from Barss 

and Weitz 2006, Table 1, Beta-to-gamma dose 

Ratios for Pacific Test Sites, Table 3, Beta-to 

gamma Ratios for eye Exposures, and Table 7, 

Standard Distances from Source Plane for 

Various Anatomical Locations. 
Effective Date:

12/21/2016

Revision No.

0 (Draft)

Document No./Description:

SCA-TR-2016-SP009

Page No.

16 of 16

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 

5 U.S.C. § 552a and has been cleared for distribution. 

Finding

Number

Report 

Section Finding Description NIOSH Response

7 7.4.2 

NIOSH’s guidance for the 

assignment of missed dose is based 

on assumptions that are not 

supported by facts and in the face of 

uncertainty are clearly not claimant 

favorable.

The next revision of ORAUT-TKBS-0052 will 

revise the missed dose guidance as follows:

“Assign missed dose based on the number of 

exchanges found in the dosimetry records. Also, 

compare the total of the recorded dose plus the 

missed dose to the 50% dose in Attachment A 

and assign the larger dose. In addition, for cases 

where occupation on the various islands is 

documented in the dosimetry records and their 

stay times are known, additional dose can be 

calculated in accordance with the information 

provided in DNA’s 1983 report entitled 

Operation Greenhouse 1951 related to 

calculating dose based on island occupation 

times and added to doses assigned as described 

above to account for potentially unmonitored 

exposure to fallout.” It should be noted that in 

most cases where an individual's dose was 

assigned based on cohort badging, logs were 

maintained in the individual's dosimetry records 

which documented the location and stay times 

associated with reentry activities. These logs can 

be used to estimate potential dose received 

during these reentry activities.

8 7.4.2 

Independent of other 

concerns/limitations that characterize 

the DNA dose distribution data (e.g., 

their accuracy, completeness, etc.), 

use of the 50th percentile dose as a 

coworker dose is not justified for 

PPG participants for Operations up 

to and inclusive of Operation 

CASTLE and for the subsequent 

Operations where dosimeter damage 

was an issue.

Owing to the large uncertainties in the operationspecific dose reported by DNA, the next revision 

of ORAUT-TKBS-0052, Attachment A will be 

revised to replace the 50th percentile doses with 

the 95th percentile doses to be used for coworker 

doses, as appropriate. 

9 7.4.2 

Operation-specific dose distributions 

defined by DNA must be adjusted to 

account for the MDA value of film 

dosimeters regardless of what 

percentile value is employed.

The next revision of ORAUT-TKBS-0052, 

Attachment A will be revised to ensure the 

coworker dose approach follows the guidance in 

ORAUT-OTIB-0020 with respect to the 

treatment and inclusion of potential missed dose.